Insertion of new section 144BA.

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....Commissioner in this regard. (2) The Commissioner shall, on receipt of a reference under sub-section (1), if he is of the opinion that the provisions of Chapter X-A are required to be invoked, issue a notice to the assessee, setting out the reasons and basis of such opinion, for submitting objections, if any, and providing an opportunity of being heard to the assessee within such period, not exceeding sixty days, as may be specified in the notice. (3) If the assessee does not furnish any objection to the notice within the time specified in the notice issued under sub-section (2), the Commissioner shall issue such directions as he deems fit in respect of declaration of the arrangement to be an impermissible avoidance arrang....

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.... the Commissioner to make such inquiry or cause the inquiry to be made by any other income-tax authority and furnish a report containing the result of such inquiry to it; or (ii) call for and examine such records relating to the matter as it deems fit; or (iii) require the assessee to furnish such documents and evidence as it may direct. (9) If the members of the Approving Panel differ in opinion on any point, such point shall be decided according to the opinion of the majority of the members. (10) The Assessing Officer, on receipt of directions of the Commissioner under sub-section (3) or of the Approving Panel under sub-section (6), shall proceed to complete the proceedings referred to in sub-section (1....

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.... shall, for the purposes of this section, constitute one or more Approving Panels as may be necessary and each panel shall consist of three members including a Chairperson. (16) The Chairperson of the Approving Panel shall be a person who is or has been a judge of a High Court, and- (i) one member shall be a member of Indian Revenue Service not below the rank of Chief Commissioner of Income-tax; and- (ii) one member shall be an academic or scholar having special knowledge of matters, such as direct taxes, business accounts and international trade practices. (17) The term of the Approving Panel shall ordinarily be for one year and may be extended from time to time up to a period of three years. (1....